Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
Common Issues #6 MIL entries
o Missing information o Transactions not logged #5 Inadequate or non-existent training #4 Lack of documentation regarding date of notification for filed SARs
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Common Issues #3
Lack of review of MTLs for suspicious activity #2 Automated data program review not completed o Pit ratings – Not just an internal document • Chip Walking/Structuring o Bills-in reports o Kiosk transactions #1 SAR Reporting o Lack of documentation regarding unfiled SARs
o Not properly identifying transactions as a failure of not performing items above o Not filing at all
30
BlueBird, CPAs
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